CRA Clock

24 hours starts the moment you know.

The EU Cyber Resilience Act reporting clock, as a GitHub Action. CRA Clock reads your lockfiles, writes a CycloneDX SBOM, checks every component against OSV, CISA's Known Exploited Vulnerabilities catalog and FIRST EPSS, and the moment something you ship is actively exploited it opens an issue with the Article 14 deadlines and pre-filled ENISA drafts.

Website · Install · What it does · Outputs · Security · CRA primer

The scanner on craclock.gautamkhosla.com, run on its built-in demo project (a Java service still shipping Log4Shell). The Action applies the same tiers to your lockfiles on every push.

Quickstart

Add these steps to a job (the full workflow, with the schedule, permissions and artifact upload, is under Install):

- uses: actions/checkout@v5
- uses: GautamTalksDev/cra-clock@v1
  with: { product-name: Acme Router }

No repository to wire up yet? Scan a lockfile in your browser: nothing is installed and the lockfile never leaves your browser.

---

Why

From 11 September 2026, Article 14 of the EU Cyber Resilience Act requires manufacturers of products with digital elements made available in the EU to report actively exploited vulnerabilities (and severe incidents) through the single reporting platform set up under the CRA. For an actively exploited vulnerability:

When	What
24 hours after becoming aware	Early warning: exploited, which product, which Member States
72 hours	Notification: nature of the exploit and the vulnerability, corrective and mitigating measures
14 days after a corrective or mitigating measure is available	Final report

This applies to products already on the market; the rest of the CRA (including the SBOM obligation) applies from 11 December 2027. Large vendors have PSIRTs. Smaller teams without anyone watching their dependencies can learn about an exploited component late, for example from a customer report, while the 24 hours may already be running from the moment they could have known. CRA Clock covers actively exploited vulnerabilities in your dependencies; severe incidents are outside its scope.

Primary sources: Regulation (EU) 2024/2847 on EUR-Lex (Article 14, reporting; Article 71, dates of application) and the European Commission's CRA reporting obligations page.

Install

CRA Clock is on the GitHub Marketplace. Reference the Action by repository as shown below.

# .github/workflows/cra-clock.yml
name: cra-clock
on:
  push: { branches: [main] }
  schedule: [{ cron: '17 */6 * * *' }]     # KEV changes daily; check every 6 hours
permissions: { contents: read, issues: write }
jobs:
  clock:
    runs-on: ubuntu-latest
    steps:
      - uses: actions/checkout@v5
        with: { persist-credentials: false }
      - uses: GautamTalksDev/cra-clock@v1
        with:
          product-name: Acme Router
          open-issues: ${{ github.event_name != 'pull_request' }}
      - uses: actions/upload-artifact@v4
        if: ${{ !cancelled() }}                  # keep the SBOM and VEX when the clock fails the job
        with: { name: cra-clock, path: cra-clock/ }

Pin by commit SHA (recommended). Tags can move; a full commit SHA cannot. Pin a release's SHA and let Dependabot update it:

      - uses: GautamTalksDev/cra-clock@<full-40-character-commit-sha> # v1.0.0

Pull requests from forks. GitHub gives fork pull requests a read-only token, so issues cannot be opened. If issue creation returns 403, CRA Clock falls back to the job summary with a note instead of failing. Set open-issues: false for pull_request events (as above) and let the push and schedule runs open the issues.

What it does

flowchart LR
    R[Your repo<br/>12 lockfile formats] --> S[CycloneDX 1.6 SBOM]
    S --> O[OSV.dev<br/>affected versions]
    O --> K{CISA KEV?}
    O --> E[FIRST EPSS<br/>exploit probability]
    K -- yes --> X[EXPLOITED<br/>Article 14 clock starts]
    E -- ">= threshold" --> L[LIKELY<br/>warning]
    K -- no --> N[known advisory]
    X --> I[Issue: 24h / 72h deadlines,<br/>fix version, ENISA drafts]
    X --> V[CycloneDX VEX<br/>in_triage + evidence]

• Lockfiles: package-lock.json, npm-shrinkwrap.json, yarn.lock, pnpm-lock.yaml, requirements.txt (pinned), poetry.lock, Pipfile.lock, go.mod, Cargo.lock, Gemfile.lock, composer.lock, gradle.lockfile.
• Signal, not noise: only CISA KEV evidence (reliable evidence of exploitation in the wild) starts the clock. High EPSS is a warning. Everything else is counted in the report and listed in the VEX.
• The clock never resets: the time CRA Clock first detected the KEV listing is stored in the issue, keyed by component and CVE (not by the order OSV lists its advisory ids in), so re-runs update the countdown instead of restarting it. Close the issue when the final report is filed. That time is when CRA Clock detected the listing: your legal 24 hours run from when you became aware, so the early warning draft says "Detected by CRA Clock" and asks you to edit the time if you knew earlier. Only issues opened by a bot (the workflow token) or by the token's own account are believed.
• De-duplicated: one finding per component and CVE, however many advisory ids describe it.
• Never silently clean: if OSV advisory details or EPSS scores cannot be fetched, the advisory is marked intel-incomplete, listed in the job summary for manual review, and the job fails unless allow-incomplete-intel: true. If the CISA KEV catalog cannot be read, or comes back empty, the report says "Could not confirm exploitation status" (never "no actively exploited vulnerabilities") and the job exits 2.
• Symlinks are never followed: symlinked files and directories in the repo are skipped.

Outputs

File	What
cra-clock/sbom.cdx.json	CycloneDX 1.6 SBOM with purls and the files each component came from
cra-clock/vex.cdx.json	CycloneDX 1.6 VEX: each vulnerability, affected components, KEV and EPSS evidence
cra-clock/report.md	The job summary (also written to the GitHub step summary)
Issues labelled cra-clock	One per actively exploited vulnerability, with deadlines and drafts

Step outputs: components, exploited, likely, intel-incomplete, kev-status, sbom, vex. When the KEV catalog cannot be read, exploited is the word unknown (not 0) and kev-status is unknown; otherwise kev-status is ok.

Inputs

Input	Default
product-name	repo name	Used in reports and drafts
product-version	ref name	Recorded in the SBOM
open-issues	true	true or false. Open and update Article 14 issues. Use false on pull_request
fail-on	exploited	exploited, likely, or never. Anything else is an error
epss-threshold	0.1	A number from 0 to 1; EPSS at or above this is "likely". 0 is allowed. Anything else is an error
allow-incomplete-intel	false	true lets the job pass when some advisories could not be fully checked (they are still listed)
output-dir	cra-clock	Where files are written

Exit codes: 0 clean, 1 a fail-on condition or incomplete intelligence, 2 invalid input or an outage (for example, the CISA KEV catalog could not be downloaded, or came back empty; the SBOM, VEX and a report that says "Could not confirm exploitation status" are still written).

Try it without installing

The website scans a lockfile in your browser with the same parsers and tiers. The lockfile never leaves your browser: only package names and versions are sent to OSV.dev, and only CVE ids to FIRST. Click "Try a vulnerable demo project" to see a Java service still shipping Log4Shell (disclosed December 2021) light up.

Develop

node --test test/*.test.mjs     # parsers for every format, the clock, untrusted-text handling, KEV outages, end to end
node site/dev.mjs 8792          # the website, with a live KEV mirror

Not legal advice

CRA Clock prepares drafts and evidence; it does not submit anything for you. Check whether your product is in scope. CISA KEV is one reliable source of exploitation evidence; if you learn of exploitation another way, the clock started then.

License

Apache-2.0.